Tax Attorney in Nevada

No. Nevada is one of nine states with no personal income tax, and Article X, Section 1 of the Nevada Constitution affirmatively bars a state-level personal income tax without a constitutional amendment approved by the voters. Nevada does impose Commerce Tax on business gross revenue above $4 million under NRS Chapter 363C, Modified Business Tax on payroll under NRS Chapter 363B (general) and NRS Chapter 363A (financial institutions and mining), state sales-and-use tax at 6.85% under NRS Chapter 372 (plus county add-ons reaching roughly 8.375% in Clark County), gaming-revenue tax administered by the Gaming Control Board, and selective excise taxes. Federal income tax filed on Form 1040 with the IRS applies in full to Nevada residents.

The U.S. Tax Court holds trial sessions in two Nevada places of trial: Las Vegas (Foley Federal Building and U.S. Courthouse, 300 S. Las Vegas Boulevard) and Reno (C. Clifton Young Federal Building, 300 Booth Street). A petitioner designates the preferred place of trial on the petition under Tax Court Rule 140. Clark County, Henderson, and Boulder City residents typically calendar Las Vegas; Washoe County, Carson City, Douglas County, and Lake Tahoe residents typically calendar Reno. The Court calendars cases for trial within roughly 12 to 18 months of petition filing.

Under NRS 360.355, the Department of Taxation generally has three years from the last day of the calendar month following the quarter for which the tax is due to issue a deficiency determination. The period is extended where the return was not filed, where fraud is present, or where the taxpayer signs a written waiver. The federal IRS Collection Statute Expiration Date (10 years from assessment under IRC §6502) runs independently from the state statute of limitations.

Yes, but the two agencies audit different taxes. The IRS examines federal income tax, federal employment tax, and federal excise tax. The Nevada Department of Taxation examines state sales-and-use tax, Modified Business Tax, Commerce Tax, and a handful of state-administered taxes. A Nevada business can simultaneously face an IRS payroll audit (Form 941 issues) and a Department sales-tax audit. The two agencies share information under information-exchange agreements, and an adjustment in one forum often triggers a look at the other.

Nevada does not run a formal Offer in Compromise program in the way the federal IRS does under IRC §7122. The Nevada Department of Taxation may negotiate settlements of disputed liabilities, accept payment plans, and issue penalty waivers where reasonable cause is shown under NRS 360.419. For the federal side, the IRS OIC remains the standard mechanism for resolving a tax balance for less than the full amount when collectibility or liability is genuinely in doubt.

Your CSED is calculated from the date of assessment, which appears on your IRS Account Transcript as Transaction Code 150 (return filed) or Transaction Code 290 (additional assessment). Add ten years, then add the days for any tolling events: pending OICs, CDP hearings, bankruptcy stays, continuous absence from the United States for six months or more, and similar. The IRS records the CSED date internally on its CC ACTRA transcript; we pull this for clients as part of every engagement. The practical impact is significant — a debt assessed in 2016 may be approaching expiration in 2026, and aggressive enforcement near the CSED is common.

Probably yes for the federal trust-fund portion. IRC §6672 assesses a Trust Fund Recovery Penalty against any "responsible person" who "willfully" failed to pay over withheld taxes — the FICA and federal income-tax withholding portion of Form 941, not the employer's share. The IRS conducts a Form 4180 interview to identify responsible persons. Anyone with check-signing authority, payroll-decision authority, or knowledge of the unpaid taxes can be assessed. On the state side, Nevada Modified Business Tax responsible-person liability follows a parallel pattern for employers that withhold but fail to remit, and Department of Taxation sales-tax responsible-person liability under NRS Chapter 372 applies similarly.

Casinos issue Form W-2G for reportable wins: $1,200 or more on a slot or bingo pull, $1,500 or more on keno, $5,000 or more on a poker tournament, and $600 or more (300:1 odds) on most other games. The amount on the W-2G is reported to the IRS and matched to your Form 1040 line for other income. Gambling losses are deductible only as an itemized deduction on Schedule A, only up to the amount of gambling winnings (IRC §165(d)), and only with substantiation — player-card win/loss statements, contemporaneous logs, and receipts. Without records, the IRS will tax the gross winnings and disallow the loss offset. Professional gamblers can deduct losses against income on Schedule C as a trade-or-business, but the IRS scrutinizes the professional-gambler classification under the Groetzinger factors.

California taxes residents on worldwide income and taxes non-residents on California-source income. The Franchise Tax Board uses the nine-factor test in Publication 1031 to determine residency — physical presence days, location of immediate family, location of principal residence, professional licenses, voter registration, vehicle registration, bank accounts, and business interests, among others. A clean break requires documenting a real change of domicile to Nevada: physical move, new driver's license, new voter registration, severed California business ties where possible, and consistent paper trail. If you retain a California home, business, or family the FTB will contest the move and assert continued residency for the prior tax year. Residency audits routinely run 18 to 36 months and demand utility bills, cell-phone records, and bank statements. VTL handles these audits because California Bar admission is required to litigate FTB matters before the California Office of Tax Appeals.

Commerce Tax under NRS Chapter 363C is a gross-receipts tax on Nevada-sourced revenue above $4 million per fiscal year (July 1 through June 30). Rates are tiered by NAICS industry classification and range from 0.051% for mining to 0.331% for rail transportation, with retail trade at 0.111%, accommodation at 0.200%, professional services at 0.181%, and so on. Returns are due within 45 days after the close of the fiscal year (August 14). A business may deduct pass-through revenue, interest income, and certain other categories. A Commerce Tax credit equal to up to 50% of the tax paid is available against Modified Business Tax for the following four quarters. Late-filing penalties and interest accrue rapidly under NRS Chapter 360. Federal-side coordination matters when the Commerce Tax assessment is large enough to affect federal cash flow.

Yes. IRC §7345 authorizes the IRS to certify "seriously delinquent" tax debt — currently $62,000 for 2026, indexed annually for inflation — to the State Department, which may then deny passport renewal or revoke an active passport. The certification reverses when the debt is paid in full, an Installment Agreement is in place, an accepted OIC is in force, an active CDP hearing is pending, or Innocent Spouse Relief is in process. For Nevada casino executives, mining engineers, gaming-tech contractors, and Las Vegas entertainers who travel internationally, decertification is often urgent and can be processed in 30 days or less once the qualifying resolution is documented.

Federal tax-resolution fees vary by matter complexity. A straightforward Installment Agreement typically falls between $1,500 and $3,500. A full Offer in Compromise with Form 433 financial analysis runs $4,000 to $7,500. Audit defense depends on the audit type and the number of issues. A U.S. Tax Court petition with case workup and trial preparation generally starts at $6,000 and rises with complexity. VTL provides a written fee quote after the free consultation. Cal Bar Rule 7.1 prohibits comparisons claiming we are cheaper or faster than competitors without verifiable substantiation, so we do not market on price.

Yes. Communications between you and a licensed attorney for the purpose of seeking legal advice are protected by federal common-law attorney-client privilege, subject to the usual exceptions (crime-fraud, waiver, and so on). The narrower federally-authorized tax practitioner privilege under IRC §7525 applies to non-attorney CPAs and EAs but does not extend to criminal-tax matters. An attorney handling your tax case retains the broader privilege that survives criminal investigation.

A Tax Court trial is a bench trial — no jury — before a Judge or Special Trial Judge of the U.S. Tax Court. The session opens with calendar call where the Court hears scheduling issues. Most cases on the calendar settle before trial; the IRS Office of Chief Counsel attorney for the case meets with petitioner's counsel during the days before trial. If trial proceeds, the petitioner bears the burden of proof on most issues, presents evidence and witness testimony, and the Court issues a written opinion typically within several months of trial. Small-tax-case procedure under IRC §7463 applies to deficiencies of $50,000 or less per year and uses a simplified evidentiary standard.

Yes, generally. IRC §6331(k)(1) suspends levy action while an offer is pending and for 30 days after a rejection, and during any timely-filed Appeals review of a rejection. The IRS will not levy on you while a processable OIC is being evaluated. However, the IRS may still file a Notice of Federal Tax Lien during the OIC pendency to protect its position. CSED is also tolled during the pendency. A poorly-prepared OIC that gets returned (not rejected) does not provide the same protection — processability matters.

For an administrative redetermination hearing at the Nevada Department of Taxation and for an appeal to the Nevada Tax Commission, a taxpayer may represent themselves or appear through an authorized representative under Department rules. For judicial review proceeding in Nevada district court, an attorney admitted in Nevada is required. VTL handles the federal side of overlapping matters and coordinates with Nevada counsel where state-court litigation is necessary. Many Department disputes resolve at the redetermination or Tax Commission stage without reaching state court.